There were a number of accounts in chronicles, including one given by Hector Boece, that speak of a duel between champions at the Battle of Halidon Hill in 1336. Boece alleges that the English champion, Sir Robert Benhale, dispatched his Scottish counterpart and physical giant Stephen Turnbull as well as his mastiff in a duel that took place before the battle commenced.

Naturally, this account is somewhat dubious and is absent from the accounts of chroniclers regarded as being more accurate. This is evidence, however, that glorified single combat between champions was at least a concept by the time Boece was writing in the late 15th century.